It is important for all stakeholders who manage and interact with personal data to understand your organization’s policies, standards and rules around information protection. These documents are managed in the “Internal” section of Governance in DPDx.
Once completed, these documents are sent by email to employees and other stakeholders (for example: consultants, contractors, vendors), but can be emailed to anyone. Email and acceptance status is tracked in the “Stakeholder Comms” section of DPDx.
The Internal homepage contains a tile for each provided document.
The following documents are provided in DPDx.
- Personal Information – Program Announcement
- Allows content creation using template and your own content
- Data Privacy Policy
- Allows content creation using template and your own content
- CCTV Policy
- Allows content creation using template and your own content
- Data Protection Training & Awareness
- Allows content creation using template
- Best practices for protecting personal data
- Allows content creation using template
- Transborder Information Flows
- Allows content creation using template
- Working from Home Policy
- Allows content creation using template and your own content
- Personal Information Security Compromise Policy
- Allows content creation using template and your own content
- Data Subject Access Requests Policy
- Allows content creation using template and your own content
The pages for Internal documents have functionality that is similar to Privacy Notices. Note that all features are not available on all documents. This guide will cover one document with all features. The same procedures apply to all documents.
- Some document sections contain an introduction. You may dismiss the introduction by clicking the “X”.
- To move among documents: While in one document, click on the word “Internal” in the navigation breadcrumb (in the upper left) to return to the document listing.
- All documents have templates. For some documents, you may additionally choose to create or use your own.
- All documents have Document Status Information.
- If you decide NOT to share any of the following documents with your stakeholders, you must go into each document and set its status to ‘N/A’.
Create document
The first step is to choose your creation method (if available):
- Use template: uses a provided template; content cannot be changed
- Use my own content: begins with a provided template; then you modify content
- Use my own document: you upload an externally created PDF document which contains your content
If you are not sure which method to use, we recommend that you “Use template” and consult with your legal counsel.
WARNING: Caution if changing creation method – After you choose a content creation method, use extreme caution if you decide to change methods. Changing methods will cause all edited or uploaded content to be deleted and it cannot be recovered. There is a pop-up reminder where you must confirm your choice. If you change methods we recommend that you download a copy of your existing version before clicking the new option.
Use template
DPDx provides a template of each document with essential elements informed by US regulation. You cannot make any changes to the text in a Template Document.
Steps to create a document from template:
- Select “Use Template” (if available)
- Read and review the document to ensure it meets your needs
- Review with your legal counsel as needed
- Select status “Completed”
- Download a copy (for back-up or historical documentation)
- Note: you must click Complete in order to use the document
Use my own content
The “Use my own content” option provides you with the same content used in the Template document, which you will then modify to meet your legal and organizational needs. You may add, delete and change this document.
Steps to create a document using your own content:
- Select “Use my own content” (if available)
- Modify the document template to meet your needs
- Review with your legal counsel as needed
- From this screen, there is not an option to do a Save. Your input is saved automatically.
- Select status “Completed”
- Download a copy (for back-up or historical documentation)
- Note: you must click both Complete in order to use the document
WARNING: Caution if changing creation method – Once you have modified the initial template provided, do not click on the other creation options (“Use template” or “Use my own document”) unless you intend to delete all of your custom changes. You will not be able to recover your modifications if you change your mind.
Use my own document
The “Use my own document” option does not allow for any text input. Instead you will choose “Upload your own document” and that document will be stored in DPDx.
Steps to create a document using your own document:
- Externally create your document
- Review with your legal counsel as needed
- Save your document as a PDF
- Select “Upload your own document” and upload the PDF
- Select status “Completed”
- Note: you must click Complete in order to use the document
WARNING: Caution if changing creation method – Once you have uploaded your own document, do not click on the other creation options (“Use template” or “Use my own content”) unless you intend to delete your custom document. You will not be able to recover your modifications if you change your mind, although you can change back to “Use my own document” and upload the same document again.
Edit a document
We recommend that you review your Governance documents once or twice a year to ensure accuracy, regardless of the creation method used. This is also a good time to have a legal review of your documents.
Use template
You may not edit a document created with “Use Template”. If you wish to make changes starting with the template, choose “Use my own content”. You may need to notify stakeholders when documents change. Email and acceptance status is tracked in the “Stakeholder Comms” section of DPDx.
Use my own content
You may make changes to the content of a document that was based on a template. We recommend that you download a copy of the current document for historical documentation before you make changes. Once changes are made, from this screen there is not an option to do a Save. Your input is saved automatically. You may need to notify stakeholders when documents change. Email and acceptance status is tracked in the “Stakeholder Comms” section of DPDx.
Use my own document
Since your own document is not directly integrated with DPDx, make changes to the document in your usual method. When your updates are complete, click “Upload your own document” and upload the PDF. You may need to notify stakeholders when documents change. Email and acceptance status is tracked in the “Stakeholder Comms” section of DPDx.
Change document creation method
A document will always open into the current method of creation. You can change your document creation method. But as soon as you choose a different method, any modifications are removed. Before you begin, we recommend that you download the current version of your document.
WARNING: If you change away from “Use my own content” or “Use my own document”, all existing edited or uploaded content will be deleted and cannot be recovered.
To change methods, click on one of the other two available methods. If you are moving away from custom content, a warning pop-up appears. Click OK to continue.
Your previously-published document is removed with this action. Follow the steps in the appropriate method in “Create document” above. Change the Status to “Not started” or “In progress” if appropriate.
Delete a document
Before you begin a deletion, we recommend that you download the current version of your document.
To delete a document, change your document creation method. Doing so removes the current version.
Example:
Current notice = “Use my own content”
Choose “Use template” and click “OK” on the pop-up to confirm deletion of content. The DPDx template version appears.
Return to “Use my own content”. You will see it has been cleared of your custom content.
If you will create a new document, follow the steps in the appropriate method in “Create document” above. Change the Status to “Not started”, “In progress”, or N/A if appropriate.
Note: For the “Use my own document” method, you may also choose “Delete” to the right of the uploaded document listing.
Download a document
As you create documents, we recommend that you download copies for backup and historical documentation.
“Use template” and “Use my own content” – use the Download button
“Use my own document” – click on the uploaded document name, then use your browser’s download function.
Once you have completed your documents you are ready for the next section. Click the tab to the right of “Internal”, which is “Optional”.
